Last updated: January 31, 2020
Our Services include our websites, applications and other services that link to this Policy. This Policy describes the types of information we may collect from you or that you may provide when you use our Services, as well as our practices for collecting, using, maintaining, protecting and disclosing that information.
This Policy applies to information we collect:
System1 LLC, and the System1 Parties comply with the EU-US Privacy Shield Framework (the "EU-US Privacy Shield") and the Swiss-US Privacy Shield Framework (the "Swiss-US Privacy Shield") as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. System1 has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability (the "Privacy Shield Principles"). If there is any conflict between the policies set forth in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern or prevail.
To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/
System1 is subject to the investigatory and enforcement powers of the Federal Trade Commission (the "FTC").
Our Services are not intended for use by children under 13 years of age. No one under age 13 may provide any information to or through our Services. We do not knowingly collect personal information from children under 13 and do not target our Services to children under the age of 13. If you are under 13, do not use or provide any information through our Services. If we learn we have collected or received personal information from a child under the age of 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under the age of 13, please contact us at:
Attn: Privacy Officer
1501 Main Street
Venice, CA 90291
We collect several types of information from and about users of our Services, including information:
We collect this information:
Information You Provide to Us
The information we collect through our Services may include:
Information that you provide by filling in forms through our Services. This includes information provided at the time of registering to use our Services, subscribing to our Services, posting material, or requesting further services. We may also ask you for information when you report a problem with our Services.
Information that you provide us also includes records and copies of your correspondence (including email addresses from which any correspondence is received), if you contact us.
Information We Collect Through Automatic Data Collection or Tracking Technologies
As you use our Services, we may use automatic data collection or tracking technologies to collect certain information about your equipment, browsing actions, and patterns, including:
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (e.g. behavioral tracking).
The information we collect automatically is statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Services and to deliver a better and more personalized service to our users.
The technologies we use for this automatic data collection may include:
We do not collect personal information automatically, but we may tie this information to personal information about you that we collect or receive from other third-party sources or you provide to us.
We do not control these third-parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising or content from many providers, see Choices About How We Use and Disclose Your Information.
We use information that we collect about you or that you provide to us, including any personal information:
We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target or objective criteria.
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose personal information that we collect or you provide as described in this Policy:
We may also disclose your personal information:
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your personal information and similar data that we may collect and store:
We desire to keep you in control of the personal information you provide to us. Accordingly, you can review, correct, change, or remove the registration settings for the personal information that you provide to us and that we subsequently control. To choose not to receive future communications from us, please Contact Us.
You may also contact System1 to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
This California Privacy Rights and Disclosure section addresses the legal obligations and rights laid out in the California Consumer Privacy Act (the "CCPA") in order to comply with the requirements set forth in the CCPA for those businesses doing business in California and/or offer their services to California residents, including with respect to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with California consumers or households (collectively, "California Information").
California Information We Collected and/or Shared
This section of the Policy provides the information California residents need to exercise their rights over their California Information. Here is information about the California Information we may have collected from and shared about consumers over the twelve months prior to the Effective Date of this Policy.
In the year before the date this Policy was updated, on or through some of our Services we may have collected and/or shared (for operational purposes with providers who provide services for or to us in connection with developing, improving, providing and/or offering our Services) the following categories of California Information:
We may have collected these categories of California Information for the following purposes:
We may have obtained California Information from a variety of sources, including:
While the CCPA defines 'sale' very broadly, there is no industry-wide consensus whether enabling third parties to collect personal data via cookies and other similar tracking technologies for the purposes of delivering interest or location-based advertising and/or similar targeting activities constitutes a "sale" under the CCPA. However, a "sale" under the CCPA may be considered to include the sharing of California Information in exchange for anything of value. According to this broad definition, in the year before the date this Policy was updated, on or through some of our Services we may be deemed to have sold the following categories of California Information:
Your California Privacy Rights to Request Disclosure of Information We Collect and Share About You
If you are a California resident, California Civil Code Section 1798.83 permits you to request information about our practices related to the disclosure of your personal information by certain members of System1 and its affiliated entities to certain third parties for their direct marketing purposes. You may be able to opt-out of our sharing of your personal information with unaffiliated third parties for the third parties' direct marketing purposes in certain circumstances. Please contact us with your request.
In addition, if you are a California resident, the CCPA grants you the right to request certain information about our practices with respect to California Information. In particular, you can request the following:
You can submit a request to us for the following additional information:
To exercise your CCPA rights with respect to this information, please contact us. These requests for disclosure are generally free.
Your Right to Request the Deletion of California Information
Upon your request, we will delete the California Information we have collected about you, except for situations when that information is necessary for us to: provide you with a product or service that you requested; perform a contract we entered into with you; maintain the functionality or security of our systems; comply with or exercise rights provided by the law; or use the information internally in ways that are compatible with the context in which you provided the information to us, or that are reasonably aligned with your expectations based on your relationship with us.
To exercise your right to request the deletion of your California Information, please contact us. These requests are generally free.
Your Right to Ask Us Not To Sell Your California Information
You can always tell us not to sell your California Information by contacting us.
Once we receive and process your request, we will not sell your California Information unless you later allow us to do so.
We have implemented security measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to (or collected by) our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on or implemented through the Services.
System1 has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.
Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolutions procedures have been exhausted.
It is our policy to post any changes we make to our Policy on this page. If we make material changes to how we treat our users' personal information, we will let you know through a notice available in connection with your use of our Services after implementing such changes. The date the Policy was last revised is found at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting this Policy to check for any changes.
To ask questions or comment about this Policy and our privacy practices, contact us at:
Attn: Privacy Officer
1501 Main Street
Venice, CA 90291